A North Carolina federal judge ruled that an IHOP franchisee, Suncakes NC LLC, successfully dodged the bulk of a fired server’s discrimination and harassment lawsuit. Juanita Crouch, a former waitress at an IHOP location in Charlotte, North Carolina, had filed a suit alleging that she was propositioned for sex by a male manager and fired in retaliation for complaining about it.
U.S. District Judge Frank D. Whitney granted summary judgment to Suncakes NC LLC on the majority of Crouch’s claims, including Title VII hostile work environment, sex bias, and retaliation. The judge found that Crouch’s allegations of sexual harassment lacked sufficient corroboration, and thus, her claims could not proceed in court. The judge specifically noted that Crouch had not provided affidavits or depositions from coworkers, family members, or friends to support her accusations.
Although the judge acknowledged the alleged conduct as “reprehensible,” he emphasized that Crouch could not survive summary judgment based solely on her own self-serving statements. However, the judge allowed Crouch’s quid pro quo sexual harassment claim to remain in play, as the franchisee did not address this specific allegation in its bid for summary judgment.
In her lawsuit filed in December 2023, Crouch claimed that shortly after starting her position at the Charlotte IHOP in September 2021, a male assistant manager began sexually harassing her. She alleged that the manager made inappropriate comments, offered her rides home in exchange for sex, and subjected her to humiliating situations. Crouch also claimed that she was fired in January 2022, believing the assistant manager had influenced her termination.
The franchisee, Suncakes NC LLC, countered that Crouch’s claims of a hostile work environment did not meet the legal threshold for severity and pervasiveness. The franchisee also cited Crouch’s excessive absenteeism—missing 26 shifts out of the 56 she was scheduled to work—as the reason for her termination. The court found no evidence to suggest that Crouch’s termination was motivated by sex bias, given the attendance issues.
Additionally, the judge dismissed Crouch’s retaliation claim, as there was insufficient evidence to support the allegation that her firing was in response to complaints about the assistant manager’s behavior. The franchisee pointed to its absenteeism policy, which permits termination after more than three absences in 90 days, and argued that Crouch’s absenteeism violated this policy.
Crouch’s claims for missed wages under the Fair Labor Standards Act were also rejected due to untimeliness.
Representatives for both Crouch and the franchisee have not provided immediate comment. Crouch is represented by Wilson Frank Fong of Hensel Law PLLC, while Suncakes NC LLC is represented by Lori P. Jones of Jordan Price Wall Gray Jones & Carlton PLLC.
The case is Crouch v. Suncakes NC LLC, case number 3:23-cv-00880, in U.S. District Court for the Western District of North Carolina.
